This document discusses how President Rodrigo Duterte's policies could impact the resources industry in the Philippines. It outlines some of the key issues Duterte will handle during his six-year term, including pursuing federalism, prioritizing peace and order, and managing resource development and disputes over territories in the South China Sea. Duterte supports shifting to a federal system to decentralize power and increase autonomy for Mindanao and other regions. He is also pushing hard to curb criminality and forge peace deals to improve security, which could help attract more investment in infrastructure and resources. However, federalism is a complex reform that needs careful planning to implement in a way that works for the Philippines.

1. 1
Duterte
-­‐
A
Boon
or
Bane
to
the
Resources
Industry?
President
Rodrigo
Roa
Duterte
will
handle
many
issues
that
will
have
an
impact
on
the
resources
industry
as
he
embark
on
his
six
years
of
governance.
A
few
of
these
important
issues
include
the
proposed
shift
to
a
federal
form
of
government,
peace
and
order,
the
role
of
the
mineral
industry
in
economic
development,
renewable
energy
vis
a
vis
coal-­‐fired
power
plants,
and
the
West
Philippine
Sea
dispute
with
China.
Duterte
is
the
first
City
Mayor
and
Prosecutor
to
become
president
without
previously
holding
a
national
position
and
the
oldest
to
assume
the
presidency
at
71
years
old.
He
is
the
first
chief
executive
from
Mindanao
bringing
with
him
extensive
managerial
skills
as
mayor
of
multi-­‐cultured
Davao
City,
the
city
with
the
largest
land
area
in
the
Philippines
and
formerly
a
hotbed
of
criminality
and
insurgency
from
both
communist
rebels
and
Muslim
secessionists.
Laying
the
Grounds
for
Federalism
Duterte
was
one
of
advocates
for
the
push
for
federalism
during
the
campaign
period.
Coming
from
Mindanao,
Duterte
supports
greater
decentralization,
autonomy
and
resource
sharing
for
the
South
from
“Imperial
Manila”.
To
him,
federalism
is
the
antidote
to
bureaucratic
centralism
–
a
legacy
of
old
colonial
powers
and
ruling
political
dynasties
that
cultivate
corruption
and
patronage.
When
one
thinks
of
examples
of
federalist
countries,
the
firsts
that
will
always
come
to
mind
are
the
United
States
of
America
and
Commonwealth
of
Australia.
The
calls
for
charter
change
have
been
persistent
over
the
years
as
many
agree
that
the
1987
Constitution
is
flawed.
Bills
calling
for
an
amendment
or
revision
of
the
present
constitution
have
not
prospered
as
many
argued
that
it
is
nothing
but
a
veiled
attempt
of
the
incumbent
Chief
Executive
to
be
given
a
term
extension.
Presently,
the
idea
for
a
charter
change
is
not
about
giving
the
sitting
president
a
term
extension
but
most
likely
shifting
from
a
unitary-­‐presidential
system
to
a
federal-­‐parliamentary
form
of
government
through
an
elected
constitutional
convention.
The
Citizens
Movement
for
a
Federal
Philippines
noted
that
the
current
unitary
system
breeds
inefficiency
because
of
the
following
factors:
detached
decision
making
from
the
people;
complex
and
complicated
coordination
among
the
different
government
agencies;
long
and
circuitous
communication
lines;
and
over-­‐
concentration
of
powers
in
the
central
government.
These
have
resulted
to
uneven
development,
insurgency,
and
dissatisfaction
across
the
country.1
Gamper
(2005)
enumerates
the
following
institutional
standards
that
are
present
in
federal
systems:
distribution
of
powers
between
the
central
and
constituent
units,
the
participation
of
the
constituent
at
the
central
level
of
decision-­‐making,
constitutional
autonomy
of
the
constituent
units,
fiscal
equalization
and

2. 2
intergovernmental
instruments.2
While
federalism
is
not
the
cure,
it
may
be
an
answer
to
the
country’s
problems
that
are
rooted
in
its
multi-­‐cultural
nature.3
However,
federalism’s
complex
nature
demands
careful
study
as
each
country
must
discern
for
itself
the
version
of
federalism
it
will
be
well
suited
to.
That
said,
the
constitutional
framers
must
also
be
conscious
of
the
unique
conditions
in
the
Philippines
that
will
shape
the
type
of
federation
to
be
adopted.4
The
Regalian
Doctrine
posits
the
query
on
the
implications
of
federalism
on
the
exploration,
development
and
utilization
of
natural
resources.
While
the
Regalian
Doctrine
means
that
all
the
lands
are
owned
by
the
State,
federalism
as
a
form
of
government
may
possibly
blur
the
lines
between
what
are
owned
by
the
State
as
a
whole
and
what
are
owned
by
the
federal
subdivisions
in
their
own
capacity.
The
charter
change
to
federalism
will
also
be
an
opportune
time
to
lift
the
restrictive
economic
provisions
in
the
Constitution
and
grant
more
foreign
ownership
in
certain
industries
including
energy
and
resources.
The
“Punisher”
and
His
Crusade
for
Peace
and
Order
Among
the
campaign
promises
of
Duterte
were
curbing
criminality
and
forging
lasting
peace
with
sworn
enemies
of
the
Philippine
government.
There
are
now
relentless
efforts
by
the
new
administration
to
address
common
crimes
in
urban
areas
and
renewed
focus
to
solve
insurgencies
and
terrorism
in
the
countryside.
Direct
foreign
investments
in
infrastructure
and
natural
resources
have
been
hindered
in
poverty-­‐stricken
areas
where
they
are
much
needed
because
of
security
issues.
The
Duterte
administration
recommenced
the
stalled
peace
process
with
the
communists
when
government
peace
negotiators
met
with
representatives
of
the
political
arm
of
the
Communist
Party
of
the
Philippines,
the
National
Democratic
Front
in
Oslo,
Norway
on
13-­‐14
June
2016.
Talks
with
Muslim
secessionist
groups
are
being
planned
with
Duterte
hoping
that
federalism
will
finally
be
the
solution
to
the
Mindanao
conflict.
Richard
Javad
Heydarian
who
teaches
political
science
and
international
affairs
at
De
La
Salle
University
and
a
widely
published
author
whose
commentaries
have
appeared
in
the
New
York
Times
and
the
Wall
Street
Journal,
believes
that
in
peace
talks
with
communists
and
Muslim
rebels,
Duterte
will
rely
heavily
on
Jesus
Dureza,
an
experienced
peace
negotiator
who
served
in
the
previous
Ramos
and
Arroyo
administrations.
Duterte
has
also
given
cabinet
positions,
like
the
Department
of
Agrarian
Reform
and
Department
of
Social
Welfare
and
Development,
to
progressives
forging
a
de
facto
coalition
with
the
left.
Heydarian
thinks
that
Duterte,
is
signaling
change
and
continuity,
by
forming
a
balanced
and
gender
sensitive
cabinet
with
the
right
kind
of
experience
and
inclusiveness
that
could
steer
the
country
towards
the
next
stage
of
development.
Duterte
has
pledged
to
continue
the
reforms
of
previous
administrations
while
upgrading
them
by
bringing
in
more
rapid
infrastructure
development,
agricultural
sector
revival,
and
manufacturing

3. 3
boom.
5
If
Duterte
is
true
to
his
promise,
we
may
see
a
surge
in
foreign
investments
particularly
in
Southern
Philippines,
which
has
a
tremendous
potential
to
be
the
country’s
next
growth
driver.
Mixed
Signals
on
the
West
Philippine
Sea
Dispute
and
Foreign
Policy
In
international
affairs,
Duterte’s
position
on
the
West
Philippine
Sea
is
generally
misunderstood.
He
pledges
to
try
to
implement
any
decision
of
the
Permanent
Court
of
Arbitration
in
The
Hague
currently
hearing
the
maritime
dispute,
which
is
decision
is
widely
anticipated
to
be
favourable
to
the
Philippines,
but
at
the
same
time
pragmatic
on
the
enforceability
of
the
judgment.
Duterte
said
he
is
open
to
joint
resource
development
schemes
in
order
to
overcome
intractable
sovereignty
disputes
with
China,
or
that
he
would
base
an
exchange
on
whether
China
would
build
for
the
Philippines
the
kind
of
infrastructure
investments
that
it
has
built
in
Africa.
However,
both
of
these
propositions
rest
on
a
prior
agreement
not
to
discuss
sovereignty
issues.
Duterte
considers
the
Philippine
claims
to
be
valid
but
is
willing
to
set
them
aside
for
the
moment
if
China
is
also
willing
to
do
so.
6
Duterte’s
appointed
Secretary
of
Foreign
Affairs,
Perfecto
Yasay,
Jr.
has
stated
that
the
Duterte
administration
would
wait
for
the
decision
of
the
arbitration
panel
prior
to
exhausting
all
negotiation
routes
for
peaceful
resolution
knowing
fully
well
that
the
Philippines
cannot
engage
in
war
with
China.
While
Yasay
knows
that
Manila’s
ability
to
enforce
any
positive
decision
is
limited,
the
Duterte
administration
may
think
that
such
a
conclusion
would
strengthen
its
hand
in
future
talks.
Duterte
reportedly
confirmed
this
fact
in
his
telephone
conversation
with
U.S.
President
Barrack
Obama
that
he
is
open
to
bilateral
talks
with
China
if
there
would
be
difficulty
in
enforcing
an
impending
favourable
decision
from
the
tribunal.
Heydarian
believes
that
in
foreign
and
defense
policy,
Duterte
is
expected
to
adopt
an
equilateral
balancing
strategy,
similar
to
the
Ramos
and
Arroyo
administrations,
reaching
out
to
both
China
and
America
without
siding
with
any
against
the
other.7
For
Duterte,
China
represents
a
unique
opportunity
to
develop
the
Philippines,
and
he
prefers
diplomacy
and
dialogue
rather
than
confrontation
and
deterrence.
Some
analysts
however
are
confused
with
Duterte’s
rhetoric
–
on
one
hand
he
suggests
a
willingness
to
engage
China
bilaterally
over
the
crisis
in
exchange
for
Chinese
economic
investment,
on
the
other
he
proposes
a
multilateral
roundtable
discussion
that
China
would
certainly
oppose.
The
shifting
policy
position
is
likely
to
pose
challenges
for
the
Philippines’
key
external
partners—the
United
States,
Japan
and
Australia.
Australia
on
its
part
is
considering
the
broader
implications
for
its
defence
diplomacy
with
the
Philippines
under
Duterte,
given
its
strategic
location,
and
its
approach
to
maritime
security,
counterterrorism
and
other
aspects
of
regional
security.
If
Duterte
begins
to
shift
the
Philippines
defence
posture
to
one
that’s
more
accommodating
of
China
in
the
South
China
Sea,
perhaps
through
bilateral
arrangements
or
by
side-­‐stepping
the
outcome
of
the
arbitration,
he
would
undermine
efforts
to
strengthen
the
rules-­‐based
international
order
that

4. 4
fundamentally
says
‘might
does
not
make
right’,
and
which
is
a
key
assumption
underpinning
Australian
defence
policy.
8
Needless
to
say,
the
West
Philippine
Sea
tension
has
seriously
affected
business
decision
to
pursue
further
exploration
work
in
the
disputed
area
amidst
armed
threat
to
seismic
vessels
and
drill
ships.
Unless
there
will
be
an
acceptable
solution
to
the
contending
parties,
the
Philippines
will
see
a
dearth
of
exploration
activities
in
its
exclusive
economic
zone
along
the
Northwest
Palawan
shelf.
Renewable
Energy
and/or
Coal-­‐Fired
Power
Plants?
The
relative
high
cost
of
electricity
and
the
unstable
supply
particularly
in
the
South
have
dampened
investors’
enthusiasm
in
the
Philippines.
For
the
Duterte
administration,
balancing
power
supply
problems
with
environmental
issues
will
be
a
major
undertaking.
Environmental
groups
are
asking
Duterte
to
promote
renewable
energy,
cancel
all
twenty-­‐seven
(27)
coal-­‐fired
power
plant
projects
in
the
pipeline
and
phase
out
the
nineteen
(19)
existing
power
plants
that
run
on
coal.
Renewable
energy
developers
that
the
Philippines’
meeting
its
commitments
made
in
Paris,
which
is
a
seventy
percent
(70%)
reduction
in
carbon
emission,
is
a
step
in
the
right
direction.
The
Department
of
Energy
(“DOE”)
under
the
Aquino
administration
pushed
for
the
industry
to
source
30
percent
of
its
energy
requirements
from
coal,
30
percent
from
renewable
energy
and
another
30
percent
from
natural
gas.
The
remaining
10
percent
will
come
from
oil-­‐based
power
plants,
including
an
open
option
for
nuclear
energy.
In
support
of
the
30-­‐30-­‐30
energy
mix,
the
Climate
Change
Commission
(“CCC”)
embarked
on
a
virtual
crackdown
on
coal
power
generation
under
an
“urgent
and
comprehensive”
review
of
the
government’s
energy
policy.
Former
President
Aquino
signed
Commission
Resolution
No.
2016-­‐001,
which
mandated
the
CCC
to
do
“a
national
policy
review
and
framework
development
on
energy,
through
a
whole-­‐
of-­‐nation
approach,
in
accordance
with
a
low
carbon
development
pathway
and
national
goals
and
targets
for
climate
change
mitigation
and
adaptation,
disaster
risk
reduction
and
sustainable
development.”
In
the
resolution,
the
DOE,
Department
of
Environment
and
Natural
Resources
(“DENR”),
and
the
National
Economic
Development
Authority
are
urged
to
harmonize
policies
and
regulations
on
new
and
existing
coal-­‐fired
power
plants
and
assess
their
impacts
on
the
environment.9
On
the
other
hand
the
National
Renewable
Energy
Board
(“NREB”)
recommended
that
the
new
government
level
the
playing
field
between
fossil-­‐fuel
plants
and
indigenous
renewable-­‐energy
resources
by
strictly
implementing
the
Clean
Air
Act,
Water
Code
and
other
environmental
laws,
and
by
removing
the
automatic
pass-­‐through
of
fuel
costs
to
consumers
(this
provision
ensures
the
profits
of
fossil-­‐fuel
plants
by
shielding
them
from
price
fluctuations).
The
NREB
also
recommended
the
full
implementation
of
the
mechanisms
and
incentives
under

5. 5
the
RE
Act
of
2008
and
fast-­‐tracking
of
the
approval
and
permits
for
renewable-­‐
energy
projects
at
all
levels.10
However,
it
may
be
worth
remembering
that
the
issue
on
renewable
energy
and
coal-­‐fired
power
plants
was
asked
of
Duterte
during
the
presidential
debates.
In
response,
he
said
that
the
United
Nations
should
first
focus
on
sanctioning
developed
nations,
who
he
believes
contribute
more
pollution
than
the
Philippines.
He
further
explained
that
the
country
needs
energy
to
industrialize,
thus
the
need
for
more
energy
sources.
"It's
not
fair.
I'm
not
saying
coal
is
right,
but
I'm
just
saying,
itong
United
Nations
and
industrial
countries
are
really
hypocrites.
Gusto
nila,
'di
bayaran
nila
tayo,
or
they
supply
us
with
hydro,
solar,
mahal
'yan.
Ngayon
kung
idinamay
nila
tayo,
sila
naman
ayaw
maniwala,
and
yet
itong
United
Nations
hypocrisy
because
they
cannot
enforce
sanctions
against
those
who
are
violating,
everyday
there
is
sprouting
up
so
many
coal
fired
power
plants.
We
only
contribute,
I
said,
to
the
carbon
footprints
so
very
little.
And
yet,
we
are
a
growing
country,
we
need
to
industrialize,
we
need
energy.…
xxx"11
Duterte’s
Energy
Secretary
Alfonso
G.
Cusi
will
review
the
target
energy
mix
set
by
the
Aquino
administration
to
determine
its
rationale.
Until
he
meets
with
DOE
experts,
he
is
not
ready
to
give
an
ideal
combination
of
fuel
sources
but
whatever
the
outcome
of
the
review
is,
coal
would
remain
a
significant
part
of
the
country’s
energy
portfolio.
Mr.
Cusi
said
he
would
also
look
into
the
available
options
for
the
Bataan
nuclear
plant,
the
feasibility
of
putting
up
a
facility
for
liquefied
natural
gas,
how
to
bring
down
power
rates,
the
connectivity
of
the
transmission
grid
to
Mindanao,
and
a
new
round
of
feed-­‐in-­‐tariff
rates
for
renewable
energy
power
plants.
Bleak
Forecast
on
the
Mineral
Industry
Of
all
the
resources
policies
enunciated
by
Duterte
it
is
his
position
on
mining
that
has
brought
considerable
apprehensions
if
not
frustration
to
the
resources
industry.
In
a
business
summit
held
in
Davao
City,
Duterte
promised
to
conduct
a
comprehensive
review
of
all
mining
permits
issued
by
the
government
the
concessions
they
allow.12
The
president
has
reiterated
that
he
is
not
anti-­‐mining,
as
he
believes
that
mining
is
a
key
player
in
the
Philippine
economy13.
Presidential
Spokesperson
Ernesto
Abella
says,
“responsible
mining
plays
a
key
role
in
the
Philippines”.
For
Duterte,
“The
keyword
here
is
responsible
hence,
if
you
cannot
do
it
right,
then
get
out
of
mining.”14
Duterte
cited
the
big
mining
companies
as
the
reason
for
environmental
destruction
and
dared
the
mining
industry
to
“shape
up”.15
The
President’s
stance
on
mining
was
further
put
to
question
when
he
appointed
Regina
Paz
“Gina”
Lopez,
a
known
anti-­‐mining
advocate
and
scion
of
a
powerful

6. 6
family
with
business
interests
in
media
and
energy,
as
DENR
Secretary.
When
news
broke
out
that
she
had
accepted
the
offer
to
be
DENR
Secretary,
mining
and
oil
stocks
plunged
by
4.09
percent
at
the
end
of
trading
on
21
June
2016
despite
the
overall
index
gaining
1.33
percent.16
Market
analysts
say
that
the
dump
on
mining
stocks
on
was
because
of
the
expectations
that
regulations
for
mining
might
become
more
challenging
under
the
new
administration.17
Upon
her
acceptance
of
the
position
offered
by
Duterte,
Lopez
said
there
was
no
such
thing
as
responsible
mining
as
the
industry
caused
suffering
and
injustice
especially
in
poor
areas.18
Lopez
has
promised
to
clamped
down
on
open
pit
mining
operations,
nickel
laterite
and
coal
mining,
extractive
industries
in
Palawan,
and
coal
fired
power
plants.
She
has
started
by
strictly
enforcing
DENR
Administrative
Order
No.
2015-­‐07
requiring
compliance
for
all
metal
miners
with
the
ISO
14001
standard
which
lays
out
best
practices
in
environmental
management.
She
does
admit
however,
that
she
was
not
“the
usual
choice”
for
such
position
because
of
her
anti-­‐mining
advocacy
but
she
says
she
is
open
to
meeting
pro-­‐mining
advocates
so
she
could
make
suggestions
on
how
to
address
the
concerns
in
the
industry.
Upstream
Petroleum
Industry
-­‐
Hanging
in
the
Balance
The
new
government
must
also
address
two
major
issues
adversely
affecting
petroleum
exploration
and
development
–
the
Resident
Marine
Mammal
case
and
service
contractors’
income
tax
under
Presidential
Decree
No.
87.
In
“Resident
Marine
Mammals
vs.
Sec.
Reyes”
case,
the
Supreme
Court
noted
that
since
the
President
was
not
the
signatory
to
Service
Contract
No.
46
and
the
same
was
not
submitted
to
Congress,
SC
46
was
null
and
void.
This
was
despite
the
fact
that
then
President
Gloria
Macapagal-­‐Arroyo
granted
a
Special
Authority
to
then
DOE
Secretary
Vicente
Perez
and
that
Congress
had
been
notified
of
the
execution
of
SC
46.
The
contractors
relied
on
good
faith
on
the
representation
of
the
Philippine
government
that
the
signature
of
the
DOE
secretary
is
sufficient
and
validly
binds
the
government.
To
the
industry,
it
is
an
“operative
fact”
that
after
the
execution
of
service
contracts
that
are
only
signed
by
the
DOE
Secretary,
services
were
actually
rendered
and
continue
to
be
rendered.
Thus,
not
only
has
the
contractors
already
spent
millions
for
their
respective
projects,
the
government
has
conversely
benefited
from
such
transactions.
The
industry
also
expressed
its
alarm
and
deep
concern
regarding
COA
Decision
No.
2015-­‐
115,
affirming
a
Notice
of
Charge
directing
the
DOE
to
collect
P53
billion
from
the
SC
38
Consortium
(composed
of
Shell
Philippines
Exploration
B.V.
Chevron
Malampaya
LLC,
and
PNOC
Exploration
Corporation).
Contrary
to
the
COA
Decision,
the
Philippine
government
through
the
DOE
has
represented
that
Presidential
Decree
No.
87
[Section
l
8(b)]
and
Presidential
Decree
No.
1459
(Section
1)
clearly
provided
that
the
Contractor's
income
tax
forms
part
of
the
60%
Government
share.

7. 7
All
of
the
active
petroleum
service
contracts
with
the
government
follow
the
DOE’s
interpretation
that
the
Contractor's
income
tax
forms
part
of
the
60%
government
share.
The
issue
is
now
under
arbitration
proceedings.
In
light
of
the
foregoing,
the
industry
calls
on
the
new
administration
to
ensure
the
sanctity
of
contracts
and
the
rule
of
law,
particularly
for
long
term
contracts
involving
substantial
investment
by
foreign
and
local
investors.
In
addition
to
these
game
changers,
the
industry
raises
issues
that
are
currently
hounding
the
industry
which
includes:
Processing
time
and
bureaucracy
in
relation
to
approval
of
Tax
Exemption
Certificates;
Customs,
Immigration,
and
Quarantine
issues;
Effluent
standards
and
water
classification
regulations
by
the
DENR;
exploration
on
ancestral
domain
claims
and
free
prior
and
informed
consent
under
the
Indigenous
People’s
Rights
Act;
and
Amendment
of
Executive
Order
No.
556
to
provide
flexibility
to
Philippine
National
Oil
Company
–
Exploration
Corporation
in
farming
in
and
out
of
service
contracts.
Conclusion
Despite
Duterte’s
unorthodox
style
and
controversial
statements
on
issues
relating
to
the
resources
industry,
he
must
reassure
the
business
community
that
his
government
can
take
the
Philippines
to
the
next
level
of
inclusive
economic
growth
through
adherence
to
the
rule
of
law,
respect
for
the
sanctity
of
contracts
and
the
country’s
international
obligations,
ease
of
doing
business
by
automating
and
streamlining
the
permitting
process,
and
addressing
bottlenecks
in
infrastructure.
The
best
assurance
he
can
give
to
the
industry
is
using
his
mandate
and
political
capital
to
reestablish
law
and
order
and
push
his
economic
agenda
to
include
charter
change
and
other
legislative
initiatives
that
will
open
the
economy
to
fair
competition
and
leveling
the
playing
field
for
all
stakeholders.
Fernando “Ronnie” Penarroyo is the Managing Partner of Puno and Penarroyo Law
Offices (www.punopenalaw.com). He specializes in Energy and Resources Law, Project
Finance and Business Development.
1 Cureg, Elyzabeth F. and Matunding, Jennifer F. Federalism Initiatives in the Philippines (2006).
Available at http://localgov.up.edu.ph/federalism-and-multiculturalism-cureg-and-matunding-
federalism-initiatives-in-the-philippines.html
2 Móntes, Jr., Raphael N. Understanding Federalism (2006). Available at
http://localgov.up.edu.ph/federalism-and-multiculturalism-montes-understanding-
federalism.html, citing Gamper.
3 Id.
4 Id.
5 Soong, Martin, Pugnacious Duterte may need to temper rhetoric as Presidential era begins
Martin Soong, CNBC.com
6 Rood, Steven, Asia Foundation

8. 8
7
Soong, Martin, Pugnacious Duterte may need to temper rhetoric as Presidential era begins
Martin Soong, CNBC.com
8 Davis, Malcolm, What does Rodrigo Duterte mean for South China Sea tensions? 12 May 2016
9 http://business.inquirer.net/211497/boom-in-renewables-drives-energy-remix.html
10 Great Expectations, the Philippine version: A ‘wish list’ for the Duterte administration, Business
Mirror – 12 May 2016
11 ABS-CBN News. What Presidential Bets Think About Climate Change, Renewable Energy.
Available at http://news.abs-cbn.com/nation/03/20/16/what-presl-bets-think-about-climate-
change-renewable-energy, last accessed 27 June 2016.
12 Jiao, Claire. Mining Has Place in Duterte Economic Agenda – MVP. Available at
http://cnnphilippines.com/business/2016/06/22/manny-pangilinan-rodrigo-duterte-gina-lopez-
mining-economic-agenda.html last accessed 27 June 2016
13 Romero, Alexis and Adel, Rosette. Duterte Camp Says Mining Key Player in Philippine
Economy. Available at http://www.philstar.com/headlines/2016/06/23/1595899/duterte-camp-
says-mining-key-player-philippine-economy, last accessed 27 June 2016
14 Id.
15 GMA News. Duterte Accuses Big Mining Firms of Destroying the Environment. Available at
http://www.gmanetwork.com/news/story/568799/money/companies/duterte-accuses-big-
mining-firms-of-destroying-the-environment, last accessed 27 June 2016
16 Pazzibugan, Dona Z., Dumlao-Abadilla, Doris, and Yee, Jovic. Gina Lopez Spooks Mining
Stocks. Available at http://business.inquirer.net/211271/gina-lopez-spooks-mining-stocks, last
accessed 24 June 2016.
17 Id.
18 Domingo, Ronnel W. Gina Lopez: Where there’s mining, there is also poverty. Available at
http://business.inquirer.net/211327/gina-lopez-where-theres-mining-there-is-also-poverty, last
accessed 24 June 2016